Was Garage Foreman’s Workplace Auto Wreck Key to Indefinite Leave?

What Do You Think?

A recent federal case addressed whether medical leave is a reasonable accommodation under the ADA when an employee doesn't say when he's returning. The case involved a city garage foreman who was seriously injured in an automobile accident at work in April 2021. 

After the accident, the foreman suffered fatigue, pain in his hip, back, neck, and leg, headaches, and other issues. The employer accommodated him by allowing him to stay home until May 3, 2021, when he returned on a light-duty basis. 

Due to his ongoing medical challenges, the foreman took leave based upon doctor's notes submitted on July 21, 2021; September 1, 2021; October 6, 2021; November 15, 2021; December 1, 2021; January 18, 2022; January 26, 2022; March 9, 2022; April 20, 2022; June 1, 2022; June 28, 2022; July 13, 2022; and August 10, 2022.

The employer informed him that it expected him to return on August 25, when his most recent doctor's note would expire. Instead, the foreman submitted another doctor's note stating he would be off work six more weeks. 

The employer fired him, stating it was unable to continue holding the position vacant due to "operational demands." The foreman sued the employer under the ADA for failing to reasonably accommodate him. 

To establish a failure to accommodate claim, an employee must show:

• He is disabled; 
• He is otherwise qualified for the position; and
• The employer failed to reasonably accommodate him. 

It’s up to the employee to show that an accommodation he proposed is reasonable.

Did the employer violate the ADA?

A. No. It wasn’t required to keep the job open indefinitely, especially when its operational demands required someone to carry out the foreman’s duties.

B. Yes. An employer must keep providing medical leave as an accommodation as long as an employee needs it if the employee was injured at work.

If you selected A, you agreed with the court in Haack v. Lapeer County Road Commission, No.  23-12273 (E.D. Mich. 08/19/25), which concluded that the employer did not violate the ADA by refusing to extend the foreman’s leave indefinitely. 

The court rejected the foreman’s argument that the employer should have accommodated him by giving him more leave. “[T]he ADA does not require an employer to provide leave of an indefinite duration,” the court wrote. An accommodation that has no reasonable prospect of enabling the employee to go back to work in the identifiable future is not reasonable.

The court also pointed out that the employer went to significant lengths to accommodate the foreman. It did so by granting him multiple extensions of medical leave for more than a year. Where an employer has already provided substantial leave, an accommodation that will require additional significant leave, with no clear prospect of the employee recovering, is objectively unreasonable, the court said.

The court ruled in the employer’s favor. Simply Research subscribers have access to the full text of the decision.

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